AusALPA recognises that considerable progress has been made toward finalising Part 135. However, there remain some contentious issues and we are cautious about how much traction the TWG feedback has gained in refining these operational parts.

AusALPA was certainly gratified to see that a number of our previous concerns have been addressed. We recognise the significant increase in data points examined and applaud the transparency that they bring to both the experimental technique and the results

AusALPA member association representatives participated in the Part 91 Technical Working Group (TWG) and have noted positively that many of the items identified for further work have indeed been addressed by CASA.

AusALPA recently learnt of the proposal by Airservices Australia (AsA) to trial Class E airspace in Tasmania through our participation at an AsA chaired meeting held after the TAS RAPAC meeting (April 11th). We were previously unaware of any industry-based initiatives to amend the airspace classification and configuration.

AusALPA supports the need to amend the Part 139 and its associated Manual of Standards specifically to align with ICAO Annex 14, except where there is a valid reason (e.g. terrain constraints) not to do so.

The Association has been member of the PIR139 Working Group, along with various major industry stakeholders. We consider the review to have been comprehensive and that the review process has provided broad consultation within the industry.

As the only stakeholders constantly exposed to these specific environmental risks, AusALPA’s greatest disappointment in the evolution of Guideline B is the apparent inability of the safety message to be heard over the economic development noise created by those decision-makers comfortably remote from the potential accident site. That disappointment stems particularly from the failure of the Civil Aviation Safety Authority to provide robust insider advice to NASAG on all safety matters, properly informed by actual operational experience.

More than any other stakeholders, our members sample the positives and negatives of our approach to airport safeguarding every day. Consequently, AusALPA is committed to the NASF and the Guidelines as well as the long-term strategy of a single broadbased national approach to safeguarding aviation infrastructure at all levels of government across Australia.

AusALPA notes that several countries have adopted mandatory registration and minimum knowledge standards for all RPAS operators, or are moving towards this. On the other hand, Australia has an estimated 50,000 RPAs, the vast majority of which are unregulated in any active sense of the word – the vehicles are unidentified and their operators are mostly unidentifiable, untrained and knowledgeable only to the extent of their own self-interest.